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Physician Payments Sunshine Act - Open Payments

Announcements:

  • From CMS:  payment data for calendar year 2015 is available for review and dispute beginning April 1, 2016.
  • The deadline for submitting disputes is expected to be May 15, 2016.
  • 2015 payment data will be made available to the public on or about June 30, 2016.
  • View publically accessible 2014 and 2013 payment data
  • Any questions from journalists, other members of the media or any other outside organization regarding payments listed on the Open Payments web site should be referred to JHMedia@jhmi.edu.

Note: The information on this site is provided to members of the Johns Hopkins Medicine Community as a resource for the Physician Payments Sunshine Act, which is also referred to as Open Payments. 


Overview of the Sunshine Act and Implications for Johns Hopkins Physicians

The Sunshine Act requires that detailed information about payments and other “transfers of value” worth over $10 from manufacturers of drugs, medical devices and biologics to physicians and teaching hospitals be made available to the public. A physician is defined as a M.D., D.O., D.D./D.D.M., D.D.S., D.P.M., O.D. and D.C.P. who is licensed in any state in the U.S., whether or not they are practicing. The Act does not affect faculty and staff members who are not physicians.

The Act has implications for Johns Hopkins physicians who consult, serve on scientific advisory boards, or engage in other compensated activity in a personal capacity for manufacturers of drugs, devices or biologics.  Details of the compensation for these activities, including the purpose of the payment, are posted on a publicly accessible website that is maintained by the federal Centers for Medicare and Medicaid Services (CMS).

Physicians may review and, if necessary, dispute reported payments. Individual physicians, not the physician's employer, are responsible for reviewing the accuracy of reported data and submitting disputes if the data are inaccurate.

The first cycle of payment data (covering payments made August 1 through December 31, 2013) became publicly accessible in September 2014.  This information was subsequently updated in December 2014 to include previously disputed payments.  The second cycle of payment data covered the calendar year 2014 and became publicly accessible on June 30, 2015.  The third cycle covering payments for calendar year 2015 is currently underway.  Physicians can view their 2014 and 2013 payment data by searching for their name on the Open Payments web site: https://openpaymentsdata.cms.gov/search


Key Dates and Important Information

  • Manufacturers have reported to CMS any payments made to physicians during the calendar year 2015 and any corrections to previously reported payment data.
  • We expect the review and dispute period to begin April 1 and close on May 15, 2016.
  • Manufacturers must submit corrected payment data to CMS by May 30, 2016.
  • 2015 payment data will be available to the public on June 30, 2016.
  • Physician payment data includes individual general payments as well as institutional research payments for which the physician is identified as a Principal Investigator.

Registration:

In order to review and dispute reported payments, physicians must be registered in the Open Payments system.  Registration is a two-step process.  Physicians must first register in the CMS Enterprise Identity Management (EIDM) System and then register in the Open Payments system. 

Registration information is available at cms.gov/Regulations-and-Guidance/Legislation/National-Physician-Payment-Transparency-Program/Physicians.html

For step-by-step instructions on the registration process, click here

If you registered previously, you may be required to reset your password.  Accounts are locked if there has been no activity within the past 60 days and deactivated after no activity for 180 days.  CMS has specific requirements for passwords which can be found here

You should allow sufficient time to complete the registration process and be aware that the CMS Help Line has limited hours.

Review and Dispute: 

Beginning on or about April 1, 2016, physicians are advised to review their reported 2015 payments for accuracy and submit any disputes to Open Payments by May 15.  CMS will then notify the manufacturer of the dispute.  Physicians should work with the manufacturer to resolve the dispute and correct any inaccuracies by May 30.  Manufacturers have provided contact information in Open Payments to assist physicians in resolving disputes.  

Information about the review and dispute process is available at https://www.cms.gov/OpenPayments/Program-Participants/Physicians-and-Teaching-Hospitals/Review-and-Dispute.html

If physicians initiate disputes regarding either (i) payments of a significant dollar amount, or (ii) a significant number of individual payments, they should advise the Office of Policy Coordination at sunshine@jhmi.edu.   

To determine whether the reported payment data are accurate, physicians are advised to maintain records of the payments they receive from manufacturers.

Research Payments: 

At Johns Hopkins, research payments are made to the institution and not to individual physicians.  Research payments are displayed in a dedicated section of the Open Payments database.  The Sunshine Act requires that manufacturers identify up to five Principal Investigators in connection with research payments made to the institution.    

Physicians are able to review and dispute their designation as a Principal Investigator in connection with institutional research payments. 

  • Please be aware that CMS’ definition of Principal Investigator may differ from that used within Johns Hopkins Medicine.  As a result, manufacturers may designate co-investigators as Principal Investigators in the Open Payments database. 
  • Physicians designated as a Principal Investigator can only dispute their association with the payment.  Other payment details must be disputed by the covered recipient of the payment.
  • Payments to physicians that are related to research but not covered by an institutional research agreement may still be attributed to physicians as personal payments (e.g., travel or medical writing and editing services).

Other Key Elements of Open Payments

  • Manufacturers must collect and provide information about indirect payments as well as payments made directly to physicians.  For example, if a physician is paid indirectly through a third party (e.g., contract research organization, travel agency), the payment will be listed as a transfer from the manufacturer to the physician. 
  • Payments to physicians for serving as speakers at accredited Continuing Medical Education activities are generally not included. This can vary depending on the details of the payment.
  • Manufacturers are responsible for reporting payments to CMS; physicians and research institutions are not responsible for reporting to CMS.
  • Manufacturers must identify physicians by their National Provider Identifier (NPI), so physicians may be asked to provide their NPI to a company that has made payments to them, whether directly or indirectly.
  • Categories of payments and transfers of value to physicians include, among others, consulting fees, compensation for speaking, travel, food, entertainment, gifts, honoraria, royalties, education, research, current or prospective ownership or investment interest, etc.
  • Information about payments to teaching hospitals will be listed by hospital name. The teaching hospitals that are part of Johns Hopkins Medicine are the Johns Hopkins Hospital, Johns Hopkins Bayview Medical Center, Sibley Memorial Hospital, Suburban Hospital and Johns Hopkins All Children's Hospital.

Resources

More information about the Sunshine Act is available on this CMS website.  Please note that the CMS website is updated frequently. To receive updates from CMS, physicians may register for the listserv by emailing OPENPAYMENTS@cms.hhs.gov.

Additional information is available on the American Medical Association website at: http://www.ama-assn.org/ama/pub/advocacy/topics/sunshine-act-and-physician-financial-transparency-reports.page?linkid=popularlinksbox-1

Patients may have questions about the payments their physician received.  Suggested guidelines for responding to patient questions are available here.  Responses should be adapted for each individual situation to ensure that the information provided is accurate.

Questions?

  • For questions about registration and other technical assistance, contact the CMS Open Payments Help Line at 1-855-326-8366 or openpayments@cms.gov.  The Help Line is available Monday through Friday from 7:30 a.m.-6:30 p.m. (CST).  For step-by-step instructions on the registration process, click here.
  • For information about the review and dispute process, click here.  After noting a payment as disputed on the CMS Open Payments website, physicians must contact the manufacturer directly to resolve the dispute and correct any inaccuracy.
  • Faculty and investigators who have questions about Sunshine payment data and the School of Medicine disclosure requirements should contact policy@jhmi.edu
  • All other questions should be directed to the Office of Policy Coordination at sunshine@jhmi.edu or 410-516-5560.

​CMS procedures are subject to change and this site will be periodically updated.

Last update: March 31, 2016

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Posted February 26, 2015